1     HIGH LEVEL PRIVACY POLICY

Overall policies on roles, responsibilities, prohibited activities, and general security practices.

1.1 Purpose

Canoe values the privacy of its users (“End User(s)” or “you”) of the products, services, or platforms of our programmer clients (“Client(s)”).  This privacy policy (“Privacy Policy”) is intended to provide information concerning how Canoe collects, stores, and handles information.

Canoe complies with privacy laws like the California Consumer Privacy Act (“CCPA”) and the European Union’s General Data Protection Regulation (“GDPR”) to the extent that such privacy laws are applicable.  The CCPA defines the privacy rights and how companies have to treat and protect the personal information and privacy of California residents.  The GDPR defines the privacy rights and how companies have to treat and protect the personal information and privacy of European Union residents.

This Privacy Policy provides the information about what information Canoe collects, the purpose for which Canoe collects it, what Canoe discloses to whom, rights limiting its use, etc.

Please read this Privacy Policy carefully to understand our policies and practices regarding personal information and how Canoe will treat it.

1.2 Scope

Canoe is an advertising technology and services company that facilitates advertising via video on demand dynamic advertisement insertion (“VOD DAI”), the Canoe addressable services, and the service assurance (collectively, the “Services”).  Our Services are designed in part to deliver more relevant and interesting advertisements to End Users.  The Services include the following:

2.2.1     VOD DAI: As End Users watch a video asset on a video on demand (“VOD”) basis, Canoe may facilitate the dynamic insertion of advertisements before, during, and after such asset.  VOD DAI may be delivered across multiple VOD-enabled devices such as set-top-boxes, tablets, laptops, and mobile phones.  Canoe provides to its Clients a service assurance across these VOD-enabled devices to ensure a better consumer experience.

2.2.2     Addressable Services: Canoe provides VOD and linear addressable services.  Addressability uses data and technology to enable the delivery of relevant advertisements to certain subsets of End Users in accordance with certain industry and consumer privacy guidelines.  Addressability allows households watching the same video asset to experience different advertisements tailored to the specific interests of each household.  The addressable services may be delivered across multiple devices such as set-top-boxes, tablets, laptops, and mobile phones.  Canoe provides to its Clients a service assurance across these devices to ensure a better consumer experience.

2.2.3     Service Assurance: In order to understand whether an advertising campaign was executed or not, Canoe works with Distributors to provide reporting to our Clients.

1.3 Scope

2.3.1     Information Canoe May Collect. To deliver Services and to provide End Users with the best experience possible, some information is collected from End Users when they interact with our Clients’ and Distributors’ products, services, or platforms.  The following lists the most common information that Canoe may automatically receive or collect:

• Device identifiers: E.g., mobile advertising IDs like iOS IDFA and Android AAID, IP address, OTT/CTV IDs, gaming console IDs, proprietary IDs, or other pseudonymized identifiers such as a randomized string of characters.

• Household identifiers: E.g., Pseudonymous IDs.

• Device metadata: E.g., device type, browser type, operating system type, and settings.

• Precise geolocation: E.g., service area based on IP address.

• Segments/demographics and interests: A grouping of anonymized household or device IDs that may share a common interest, trait, or preference (a “Segment”), such as “auto intenders” or “guitar buyers.”  These Segment definitions are determined by Clients.  Canoe may also use third-party data services to understand general demographics or interests, which can be used to make inferences for creating a Segment (e.g., household income, number of household members, geographic area, retail interests) or to understand the potential audience size of a certain advertising opportunity.

• Advertisement Analytics: E.g., distributor, television content viewed, which ads were shown to which devices or households, where and what they were shown, and at what time.

• Viewing Analytics: Consumption metrics related to the viewing interaction between an End User and the applicable video asset.  Such metrics may include whether or not an End User fast forwarded through an advertisement contained within the video asset, replayed the video asset, or stopped viewing the video asset altogether.

2.3.2     Sources of the Information Canoe May Collect. Canoe may collect information from various sources:

• Distributors: Canoe may collect information from Distributors.  Please note, however, that Distributors have their own privacy policies.  Canoe will only collect and store such information as permitted by these Distributors.

• VOD DAI-enabled or Addressable Services-enabled devices: Canoe may receive certain information as End Users view a video asset enabled for one or more Services.  In these cases, Canoe is provided the End User’s television distributor when they interact with such video asset.  For example, Canoe may collect information from VOD-enabled devices such as set-top-boxes, tablets, laptops, and mobile phones after a VOD session ends.

2.3.3     How Personal Information may be used.

Canoe may use the information collected to deliver more relevant and interesting advertisements to End Users or to work with Distributors on behalf of Clients to analyze trends and create reports about how End Users react to such advertisements.  Canoe will store information only for as long as needed to use such information for the below purposes or as required by law. Such uses may include:

• Addressable Advertisement delivery: delivery of an addressable advertisement based on general demographics or interests or the general demographics or interests of a household.

• Measurement: Analytics to determine how well an advertisement was delivered.

• Attribution: Inferred determination of whether an End User acted as a result of viewing an advertisement (e.g., saw an advertisement and then purchased something).  In other words, trying to reasonably correlate whether an advertisement prompted an End User’s action, however such action is defined.

• Reporting: A report to a Client regarding the performance of an advertisement campaign.

• Fraud Detection: Preventing invalid or fraudulent advertisement traffic or malicious activity, such as those caused by bots or malware.

2.3.4     How Canoe may share Information. Information about End Users is an important part of Canoe’s business.  This information may be shared as follows:

• Clients: Canoe may disclose information to a Client only when necessary to provide the Service(s) to such Client (e.g., troubleshooting).

• Distributors: Canoe may work with third-party companies and individuals, such as payment processors, contractors, vendors, or multichannel video programming distributors, to facilitate the Services, provide the Services on our behalf, perform Service-related services, or assist us in analyzing how our Services are used (“Distributors”).  Distributors are authorized to use personal information only as necessary to provide these services to Canoe or to assist Canoe in its business activities.  Examples may include technical support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement, or otherwise assisting Canoe to provide, develop, maintain, and improve the Services.

• Third Parties or Publicly: Canoe does not sell, rent, or loan any personal information regarding End Users to any unrelated third parties.  However, Canoe may share data in aggregated or otherwise anonymized form (e.g., statistics about our Service activities).

• Law Enforcement: Canoe may disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or otherwise to comply with legal process or regulatory investigations (e.g., a subpoena, court order).

• Legal Requirements: Where Canoe believes in good faith it is necessary to comply with applicable law, to enforce our commercial agreements, or to protect the rights, property, or safety of Canoe and its employees or others.

• Merger, Sale, or Bankruptcy: In the event of a merger, dissolution, reorganization, or similar corporate event, or the sale of all or substantially all of our assets, or any due diligence relating thereto.  In such a case, the information that Canoe has collected may be transferred to, acquired by, or otherwise controlled by a third party.